In the swamp of shadow holdings – Malta’s role in the Lyoness/Lyconet/myWorld network
As announced, we are now gradually publishing the key points of reference for our work so that it finally becomes clear in what swamp of corporate constructs this system is rooted.
Behind the well-known brands Lyoness, Lyconet and myWorld lies not a corporation, but an opaque network: in addition to the official companies, there is a jungle of shell companies, holding companies and shareholdings – spread across a few, but carefully selected locations worldwide.
New documents from the WKStA proceedings 14 St 17/12m shed light on a network of companies associated with Lyoness founder Hubert Freidl. What is striking are identical addresses, recurring players and connections to companies that also appear in the Paradise Papers.
A complex network of companies with a familiar signature
Internal documents from proceedings 14 St 17/12m of the Public Prosecutor’s Office for Economic Affairs and Corruption (WKStA) paint a clear picture: for years, there was a closely interlinked network of companies in Malta that can be traced back to the same names, the same addresses and the same authorised representatives.
At the centre of this network is UTM Holding Limited, registered under number C 46560 in the Maltese commercial register. According to the documents, the shareholders are Hubert Freidl, founder of the former Lyoness Group, and Austro Consulting Ltd.
The business address: 2323, Triq il-Kapuccini, Floriana FRN 1052, Malta – an address that turns out to be the central hub of a dense network of companies.
Other companies are registered there which, according to investigation files, are described as ‘close to Lyoness’: Austro Consulting Holding Ltd., Aldebaran Holding Ltd., Aldebaran Ltd. (Werner Kaiser), and United Trade Mark Limited.
Overlaps between individuals and companies
United Trade Mark Limited is one of the most prominent players in this structure. It is owned by UTM Holding Ltd. and Austro Consulting Ltd. and in turn holds a stake in WinWinWin Company Ltd., whose shareholder is Franz Rudolf Freidinger.
These overlaps in names and individuals are no coincidence.
Several of these companies share the same address, the same shareholdings and, according to documents, often the same beneficial owners.
The individuals involved have also been known for years from the Lyoness environment:
- Hubert Freidl – economic centre of the holding structure, signatory of several financial documents.
- Peter Mühlbacher – listed several times in Maltese company registers as company secretary or director, including at Clever & Smart Holding Limited and Clever & Smart Limited.
- Gunter Rudolf Steininger – also named in the Paradise Papers databases as the person responsible for Maltese companies.
- Wolf Peter Rosenzopf – according to WKStA documents, connected to the group of companies in several transactions.
These individuals form the recurring core of a network that has existed since the late 2000s, with overlaps between Austrian companies, Maltese holding companies and private foundations.
The loan to Alexander Lerch – a touchstone for cash flows
A particularly revealing detail can be found in a promissory note from 2012:
United Trade Mark Limited granted Alexander Lerch a loan of €725,000, of which, according to the documents, €225,000 had already been paid out in 2010.
The promissory note was signed by Hubert Freidl as ‘authorised representative of the lender’.
Controversially, the loan was only secured by a lien in the land register two years after it was paid out – an unusual procedure which, according to legal experts, indicates a retrospective legitimisation of a transaction that had already been completed.
In his letter to the WKStA, the private representative points out that this loan should be accounting traceable. If this is not the case, there would be suspicion of an indirect transfer of assets – a point that is also significant in the context of possible money laundering.
Malta as a legal retreat
It is no coincidence that many of these companies are concentrated in Malta.
In the 2010s, the island nation was considered a preferred location for companies with low transparency requirements, reduced disclosure and limited insight into beneficial owners.
Especially in combination with holding structures – such as those found at UTM Holding Ltd. and its subsidiaries – this allows for an almost complete concealment of capital flows between EU countries.
The companies listed in the Paradise Papers, Clever & Smart Holding Limited and Clever & Smart Limited, also share these characteristics: they were managed by the same legal service provider in Sliema, Malta, and have personnel overlaps with the above-mentioned parties.
Investigative interest and unanswered questions
Several parties involved in proceedings 14 St 17/12m offered to provide the Public Prosecutor’s Office for Economic Affairs and Corruption (WKStA) with additional documents relating to the Maltese corporate structures. According to current information, the authorities are following up on these leads.
However, one thing is certain: the names, addresses and company connections are documented – and they point to a continuous structure that has existed for years in the environment of Lyoness and myWorld executives.
Several of the individuals mentioned, including Bruno Michl, Peter Mühlbacher and Gunter Rudolf Steininger, are also listed in the ICIJ database (Paradise Papers).
Conclusion
The available documents suggest that Malta served as a legal hub for companies associated with Lyoness for many years.
Identical addresses, recurring individuals and complex ownership structures point to a structured approach, the purpose of which was apparently to shield economic interests.
Whether these constructs pursued exclusively tax optimisation goals or also contained money laundering elements remains a question for ongoing and future investigations.
However, one thing is clear: the trail leads deeper than has been publicly known so far – and Malta apparently played a central role in this.
Note:
This article is based on publicly available sources, documented complaints from investors and an official press enquiry to Blocktrade. It is a journalistic analysis. All statements about legal risks or possible contractual constellations are to be understood as assessments, not as conclusive legal advice.
Sources:
- Documents from criminal proceedings 14 St 17/12m, WKStA Vienna
- Malta Business Registry (mbr.mt) – Extracts on UTM Holding Ltd., Austro Consulting Ltd., United Trade Mark Ltd.
- ICIJ Offshore Leaks Database / Paradise Papers (accessed: October 2025)
- Own observations and evaluations, as of 28 October 2025
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